DRAYTON COAL MINE POLLUTION REDUCTION PROGRAM ASSESSMENT AND BEST PRACTICE

DRAYTON COAL MINE POLLUTION REDUCTION PROGRAM ASSESSMENT AND BEST PRACTICE Report No: 6763 27 June 2012 A PEL Company

PROJECT TITLE: Drayton Coal Mine Pollution Reduction Program Assessment and Best Practice JOB NUMBER: 6763 PREPARED FOR: James Benson ANGLO AMERICAN (DRAYTON MANAGEMENT) DATE OF RELEASE: 27 JUNE 2012 PREPARED BY: F. Triffett APPROVED FOR RELEASE BY: J. Cox DISCLAIMER & COPYRIGHT: This report is to be read subject to the disclaimer and copyright statement located at www.paeholmes.com Queensland Environment Pty Ltd trading as PAEHolmes ABN 86 127 101 642 DOCUMENT CONTROL VERSION DATE PREPARED BY REVIEWED BY FINAL 27.06.2012 F.Triffett J.Cox Queensland Environment Pty Ltd trading as PAEHolmes ABN 86 127 101 642 SYDNEY: Suite 203, Level 2, Building D, 240 Beecroft Road Epping NSW 2121 Ph: +61 2 9870 0900 Fax: +61 2 9870 0999 PERTH: Level 18, Central Park Building, 152-158 St Georges Terrace, Perth WA 6000 Ph: +61 8 9288 4522 Fax: +61 8 9288 4400 BRISBANE: Level 1, La Melba, 59 Melbourne Street, South Brisbane QLD 4101 PO Box 3306, South Brisbane QLD 4101 Ph: +61 7 3004 6400 Fax: +61 7 3844 5858 MELBOURNE: Suite 62, 63 Turner Street, Port Melbourne VIC 3207 PO Box 23293, Docklands VIC 8012 Ph: +61 3 9681 8551 Fax: +61 3 9681 3408 ADELAIDE: 72 North Terrace, Littlehampton SA 5250 PO Box 1230, Littlehampton SA 5250 Ph: +61 8 8391 4032 Fax: +61 7 3844 5858 GLADSTONE: Suite 2, 36 Herbert Street, Gladstone QLD 4680 Ph: +61 7 4972 7313 Fax: +61 7 3844 5858 Email: info@paeholmes.com Website: www.paeholmes.com 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx ii

TABLE OF CONTENTS 1 INTRODUCTION 1 1.1 OEH Best Practice 1 1.2 PRP Requirements 1 1.3 Overview of Drayton Mine 3 1.4 Mining activity and associated emission factors 4 2 EXISTING MEASURES USED TO MINIMISE PARTICLE EMISSIONS 8 2.1 Estimated Emissions No Controls 8 2.2 Estimated Emissions Existing Controls 9 2.3 Activities Rank Existing Controls 15 2.3.1 Ranking by emissions with current controls 15 2.4 Emissions with Potential Additional BPM 16 2.4.1 Identification of additional BPM 16 3 PRACTICABILITY AND COSTS OF IMPLEMENTING ADDITIONAL BPM 21 4 PROPOSED TIMEFRAME FOR IMPLEMENTATION OF BEST PRACTICE MEASURES 31 5 MONITORING AND TRACKING THE EFFECTIVENESS OF BPM AT DRAYTON COAL MINE 32 5.1 KPI-1 - Emissions of PM 10 per tonne of ROM coal 32 5.2 KPI-2 Control of PM 10 Emissions 33 5.3 KPI-3 Opacity (Visible Dust Emissions) 33 5.4 KPI-4 Watering intensity for haul roads 33 5.5 Recommendations for Ongoing Improvement of KPIs 35 6 CLOSING/CONCLUSIONS 37 7 REFERENCES 38 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx iii

LIST OF TABLES Table 1.1: PRP Guideline requirements and report reference... 2 Table 1.2: Emission Factors... 5 Table 2.1: Summary of particulate matter emissions with no controls in place... 8 Table 2.2: Summary of current dust controls and level of control applied... 10 Table 2.3: Summary of particulate matter emissions with current controls in place... 11 Table 2.4: Activity groups ranked by TSP emissions in 2011 (with current PM controls)... 15 Table 2.5: Activity groups ranked by PM 10 emissions in 2011 (with current PM controls)... 15 Table 2.6: Activity groups ranked by PM 2.5 emissions in 2011 (with current PM controls)... 16 Table 2.7: Mass emissions applying best practice measures (kg/y)... 17 Table 3.1: BPM to reduce particulate matter emissions from haul roads... 22 Table 3.2: BPM to reduce particulate matter emissions from wind erosion on open areas... 24 Table 3.3: BPM to reduce particulate matter emissions from material transfer of overburden (includes dragline and rehandling)... 25 Table 3.4: BPM to reduce particulate matter emissions from bulldozers on overburden, coal and rehab... 26 Table 3.5: BPM to reduce particulate matter emissions from remaining activities... 27 Table 4.1: BPM to be implemented... 31 Table 4.2: BPM to be implemented should the Drayton South Project be approved... 31 Table 5.1: KPIs for BPM... 34 Table 5.2: Site specific measurements for improvements to KPI-1... 35 Table 5.3: Site specific control efficiencies... 36 LIST OF FIGURES Figure 1.1: Location of Drayton Coal Mine... 3 Figure 2.3: Watering of haul roads... 12 Figure 2.4: Water sprays on ROM hopper... 12 Figure 2.5: Partially enclosed conveyors... 13 Figure 2.4: Water sprays at conveyor transfer points... 13 Figure 2.4: Water sprays at active coal stockpiles... 14 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx iv

1 INTRODUCTION Drayton Coal Mine is operated and managed by Anglo American Coal, who hold an 88% majority share of ownership. The mine is situated between the towns of Muswellbrook and Singleton in the Upper Hunter Valley in New South Wales. The operations at Drayton include open-cut mining, and processing of Run of Mine (ROM) coal at the Coal Handling and Processing Plant (CHPP). The mine currently produces approximately 4 million tonnes per annum (Mtpa) of product coal, all of which is transported by rail to the Port of Newcastle. This report has been prepared pursuant to condition U1 of the Anglo Coal (Drayton Management) (EPL) 1323 (Appendix A). 1.1 OEH Best Practice In 2011 NSW Environment Protection Authority (EPA) published the document NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining (hereafter referred to as the Best Practice Report ) (Donnelly et al., 2011). As an outcome of the Best Practice Report, OEH developed a Pollution Reduction Program (PRP) to be included in Environmental Protection Licences for each coal mine in NSW. 1.2 PRP Requirements The PRP requires the Licensee (the mine company) to conduct a site-specific Best Management Practice (BMP) and prepare a report on the practicability of implementing additional measures to reduce emissions of particulate matter (PM). The report must include the following: The identification, quantification and justification of the measures that are currently being used to reduce PM emissions. The identification, quantification and justification of best practice measures that could be used to minimise PM emissions. An evaluation of the practicability of implementing the best practice measures. A proposed timeframe for implementing all practicable best practice measures. In preparing the report the Licensee must refer to the document entitled Coal Mine Particulate Matter Control Best Practice Site Specific Determination Guideline (referred to as the Guideline) (EPA, 2011), which details the process to be followed in the PRP (Appendix B). It also provides the required content and format of the PRP. Table 1.1 presents a summary of the Guideline requirements and a reference to the relevant section in this report. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 1

1) Identification, quantification and justification of existing measures that are being used to minimise particle emissions Table 1.1: PRP Guideline requirements and report reference 2) Identification, quantification and justification of best practice measures that could be used to minimise particle emissions 3) Evaluation of the practicability of implementing these best practice measures 4) A proposed timeframe for implementing all practicable best practice measures Guideline Requirement a. Estimate baseline emissions of TSP, PM 10 and PM 2.5 (tonne per year) from each mining activity using US EPA AP-42 emission estimation techniques for both uncontrolled emissions (with no particulate matter controls in place) and controlled emissions (with current particulate matter controls in place). b. Rank the controlled emission estimates for TSP, PM 10 and PM 2.5 emitted by each mining activity from highest to lowest. c. Identify the top four mining activities that contribute the highest emissions of TSP, PM 10 and PM 2.5. a. For each of the top four activities identified in Step 1(c) identify the measures that could be implemented to reduce emissions. b. For each of the top four activities identified in Step 1(c) estimate emissions of TSP, PM 10 and PM 2.5 from each mining activity following the application of the measures identified in Step 2 (a). a. For each of the best practice measures identified in Step 2(a), assess the practicability associated with their implementation, by taking into consideration: i. Implementation costs ii. Regulatory requirements iii. Environmental impacts iv. Safety implications and v. Compatibility with current processes and proposed future developments. b. Identify those best practices that will be implemented at the premises to reduce particle emissions. a. For each of the best practice measures identified as being practicable in step 3(b), provide a timeframe for their implementation. Report Reference Section 2.1 Section 2.3 Section 2.3 Section 2.4 Section 2.4 Section 3 Section 3 Section 4 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 2

1.3 Overview of Drayton Mine The current mining activities at Drayton Coal Mine include extraction from the open-cut operation and processing at the onsite Coal Handling and Preparation Plant (CHPP). The open-cut and CHPP operate under Development Approval 06_0202 issued on 1 February 2008. The mine provides predominantly steaming coal to export and domestic markets at a maximum of 8 Million tonnes per annum (Mtpa) of Run-of-Mine (ROM) coal. Drayton s Project Approval expires in 2017. The main activities associated with Drayton Coal Mine include: An open cut mining fleet of excavators and shovels, supports by haul trucks, dozers, graders, drill rigs and water carts. Stripping of topsoil. Drilling and blasting of overburden and ROM coal. Hauling topsoil, overburden and ROM coal to emplacement areas or the CHPP. Crushing and screening of ROM coal at the CHPP. The disposal of tailings and coarse reject within the Overburden Emplacement Areas (OEA). Progressive rehabilitation of all disturbed areas. The Drayton South Coal Project is a proposed continuation of mining at Drayton Mine by the development of open cut and highwall mining operations while continuing to utilise the existing infrastructure and equipment from Drayton Mine. The Drayton South Coal Project Environmental Assessment is currently being finalised. Figure 1.1: Location of Drayton Coal Mine 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 3

1.4 Mining activity and associated emission factors The PRP defines mining activities as: Wheel generated particles on unpaved roads. Wind erosion of overburden. Blasting. Bulldozing coal. Trucks unloading overburden. Bulldozing overburden. Front-end loaders on overburden. Wind erosion of exposed areas. Wind erosion of coal stockpiles. Unloading from coal stockpiles. Dragline. Trucks unloading coal. Loading coal stockpiles. Graders. Drilling. Coal crushing. Material transfer of coal. Scrapers on overburden. Train loading. Screening. Material transfer of overburden. The relevant emission factors for each of these activities are presented in Table 1.2. Not all of the activities listed in Table 1.2 occur at the Drayton Coal Mine. Table 2.1 presents the calculated emissions for the activities relevant to Drayton. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 4

Table 1.2: Emission Factors PRP activity Units TSP Emission Factor PM 10 Emission Factor PM 2.5 Emission Factor Source Wheel generated particulates on unpaved roads kg/vehicle Kilometres Travelled (VKT) ( ) ( ) ( ) ( ) ( ) ( ) ( ) ( ) ( ) AP-42 13.2.2 Wind erosion of overburden (a) kg/ha/h 0.1 0.5 x TSP (0.5 from AP42 13.2.5) 0.075 x TSP (0.075 from AP42 13.2.5) AP-42 11.9.7 Table 11.9-4 Loading and dumping overburden kg/t ( ( ) ( ) ) ( ( ) ( ) ) ( ( ) ( ) ) AP-42 13.2.4 Blasting kg/blast 0.52 x TSP 0.03 x TSP AP-42 11.9.7 Table 11.9-2 Bulldozing coal kg/t 0.022 x TSP AP-42 11.9.7 Table 11.9-2 Bulldozing overburden & frontend loaders on overburden kg/t 0.105 x TSP AP-42 11.9.7 Table 11.9-2 Wind erosion of exposed areas (a) kg/ha/h 0.1 0.5 x TSP (0.5 from AP42 13.2.5) 0.075 x TSP (0.075 from AP42 13.2.5) AP-42 11.9.7 Table 11.9-4 Wind erosion of coal stockpiles kg/ha/h 1.8 x u 0.5 x TSP (0.5 from AP42 13.2.5) 0.075 x TSP (0.075 from AP42 13.2.5) AP-42 11.9.7 Table 11.9-2 Unloading from coal stockpiles kg/t 0.019 x TSP AP-42 11.9.7 Table 11.9-2 Dragline kg/bcm 0.017 x TSP AP-42 11.9.7 Table 11.9-2 Trucks unloading coal kg/t 0.019 x TSP AP-42 11.9.7 Table 11.9-2 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 5

PRP activity Units TSP Emission Factor PM 10 Emission Factor PM 2.5 Emission Factor Source AP-42 13.2.4 Loading coal stockpiles kg/t ( ( ) ( ) ) ( ( ) ( ) ) ( ( ) ( ) ) (Note: AP-42 11.9-7 Table 11.9-4 has Train loading emission factor but footnote direct user to Chapter 13 for more accurate emissions factors.) Graders kg/vkt AP-42 11.9.7 Table 11.9-2 0.52 x TSP 0.03 x TSP Drilling overburden kg/hole 0.59 (PM 10 ratio assumed same as blasting AP42 11.9.7 Table 11.9-2) (PM 2.5 ratio assumed same as blasting AP42 11.9.7 Table 11.9-2) AP-42 11.9.7 Table 11.9-4 Drilling coal kg/hole 0.1 0.52 x TSP 0.03 x TSP AP-42 11.9.7 Table 11.9-4 Coal crushing kg/t 0.0027 0.0012 No data AP-42 11.19.2 Table 11.19.2-2 Material transfer of coal kg/t 0.019 x TSP AP-42 11.9.7 Table 11.9-2 Scrapers on overburden N/A kg/t 0.029 (b) No data No data AP-42 11.9.7 Table 11.9-4 AP-42 13.2.4 Train loading kg/t ( ( ) ( ) ) ( ( ) ( ) ) ( ( ) ( ) ) (Note: AP-42 11.9-7 Table 11.9-4 has default train loading emission factor but footnote directs user to Chapter 13 for more accurate emissions factors.) Screening N/A kg/t 0.025 0.0087 No data AP-42 11.19.2 Table 11.19.2-2 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 6

PRP activity Units TSP Emission Factor PM 10 Emission Factor PM 2.5 Emission Factor Source Material transfer of overburden kg/t ( ( ) ( ) ) ( ( ) ( ) ) ( ( ) ( ) ) AP-42 13.2.4 Where: A = horizontal area (m 2 ) M = material moisture content (%) s = material silt content (or surface silt content in unpaved roads) (%) u = wind speed (m/s) d = drop height (m) W = mean vehicle weight (tonnes) S = mean vehicle speed (km/h) Notes: (a) (b) An alternative method for the estimation of wind erosion from exposed areas is contained within AP-42 Chapter 13.2.5. The method takes into account site specific wind data, site-specific erodible material properties (threshold friction velocity, particle size distribution of the material eroded) and the frequency of material disturbance. Notwithstanding the data intensiveness of this approach, exercises in applying this method in to Hunter Valley mines to date (e.g. Integra Complex, Ravensworth Operations) has resulted in little or no wind initiated dust lift-off emissions being predicted from active mine sites. As such, the AP-42 Chapter 11.9.7 approach has been adopted. This is considered both conservative and applicable to the estimation of wind erosion emissions over the longer term. The equation referenced relates to topsoil removal by scraper. No data is provided within the AP-42 relating to scraper activity on overburden. Nor is this activity identified within the activities conducted at the subject mine. N/A These activities do not take place at Drayton Mine 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 7

2 EXISTING MEASURES USED TO MINIMISE PARTICLE EMISSIONS This section provides estimation of particulate matter emissions from all identified activities for the two scenarios: uncontrolled emissions (with no particulate matter controls in place) and controlled emissions (with current particulate matter controls in place). Emissions were calculated using the relevant USEPA AP-42 emission estimation techniques (see Section 1.4) for both uncontrolled emissions and controlled emissions. TSP, PM 10 and PM 2.5 emission estimates have been calculated for mining activities that occurred during January 2011 to December 2011 at Drayton Mine. Emission estimates have been made with no particulate matter controls in place (uncontrolled Table 2.1), as well as with particulate matter controls in place (controlled Section 2.2). 2.1 Estimated Emissions No Controls Table 2.1: Summary of particulate matter emissions with no controls in place Mining Activity TSP PM 10 PM 2.5 (t/year) (t/year) (t/year) Topsoil Removal - Dozers/Excavators stripping topsoil 3.3 0.5 0.3 Topsoil removal - Sh/Ex/FELs loading and rehandling topsoil 0.6 0.3 0.0 Topsoil removal - Hauling topsoil to topsoil stockpile 56.7 13.1 1.3 Topsoil removal - Emplacing topsoil 0.4 0.2 0.0 OB - Drilling 36.0 18.7 1.1 OB - Blasting 35.4 18.4 1.1 OB - Sh/Ex/FELs loading OB 9.0 4.2 0.6 OB - Dragline removing OB 405.9 71.0 6.9 OB - Hauling to emplacement 3,315.0 769.1 76.9 OB - Dozers on O/B 197.8 32.6 20.8 OB - Rehandling O/B 2.2 1.0 0.2 OB - Emplacing OB at dumps 23.6 11.2 1.7 CL - Drilling 6.1 3.2 0.2 CL - Blasting 3.0 1.6 0.1 CL - Dozers ripping 397.0 114.4 12.7 CL - Loading ROM to trucks 222.0 33.1 4.2 CL - Hauling ROM coal to dump hopper 780.8 181.1 18.1 CL - Unloading ROM coal at stockpile/hopper 222.0 33.1 4.2 CL - Rehandle ROM coal at stockpile/hopper 0.5 0.3 0.0 CL - Unloading ROM coal at ROM Pad 222.0 33.1 4.2 CL - Crushing 14.9 6.6 0.0 CL - Loading product coal stockpile 159.8 23.8 3.0 CL - Conveyors at CHPP 0.4 0.2 0.0 CL - Dozers at CHPP 0.0 0.0 0.0 CL - Loading Rejects 47.1 6.2 0.8 CL - Hauling Rejects 73.0 33.9 3.4 CL - Emplacing Rejects 47.1 6.2 0.8 CL - Loading coal to trains 0.4 0.2 0.0 WE - Exposed areas including OB dumps - unwatered 471.9 236.0 35.4 WE - Exposed areas including OB dumps - watered 52.4 26.2 3.9 WE - Active coal stockpiles 276.8 138.4 20.8 Dozers on rehab 106.2 25.1 11.1 Grading roads 90.6 31.7 2.8 Total 7,279.9 1,874.5 236.8 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 8

2.2 Estimated Emissions Existing Controls Table 2.2 presents a summary of the dust control measures currently employed at Drayton. Some of these are not listed specifically in the EPA best practice document and therefore do not correspond directly to a percentage control factor. Some of the control measures at Drayton are shown in Figure 2.1 to Figure 2.5. Emissions from current activities were recalculated taking into account various control factors for the dust controls that Drayton mine have in place. These controls, as well as the control factor applied, are listed in Table 2.2. Drayton Coal are also committed to implementing other dust controls on-site but which cannot be quantitatively measured in this PRP exercise. Such measures include: Installation of a new TEOM in 2012. Adopting a predictive weather forecasting model to be used to make dust mitigation decisions in advance of dust generation conditions. Committing to altering operations to stop machinery based on real-time data. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 9

Drilling Hauling Table 2.2: Summary of current dust controls and level of control applied Mining Activity Wind erosion - Exposed areas & overburden emplacement area Grading roads Wind erosion and maintenance Coal stockpiles Bulldozers on OB Blasting Dragline Control measure currently in place Level of control applied (%) Water injection while drilling 70 Skirts on drill vehicles Not quantified Water sprays 75 Use of larger vehicles Not quantified Water applied to 10% of the area 50 Rehabilitation goals Not quantified Vegetative wind breaks 30 Water sprays 50 Grader speed reduction from 16 km/h to 8 km/h Not quantified Some coal bypasses stockpiles Not quantified a Reduced pile height Not quantified Minimise travel speeds and distance Restricted to 2 nd gear Not quantified on haul roads Travel routes kept moist Not quantified b Delay shot to avoid unfavourable weather conditions Not quantified Minimise area blasted Not quantified Minimise drop height Not quantified c Modify activities in windy conditions Not quantified Minimise site casting Not quantified Loading and dumping overburden Modify activities in windy conditions Not quantified Minimise drop height from 3 m to 1.5 m 30 Dumping ROM coal to ROM hopper One side of hopper covered and the other three sides sprays when dumping is triggered 50 Water applied at transfers Not quantified Belt cleaning and spillage Conveyors and transfers minimisation Not quantified Wind shielding roof or side wall 40 Application of water at transfers 50 Limit load size to ensure coal is Train and truck load out and transportation below sidewalls Not quantified Maintain a consistent profile. Not quantified a Whilst this is not included as a control efficiency factors in the emissions inventory, 2% of the total product coal will bypass stockpiles and is loaded straight to trains. b A control factor of 75% is already applied to watering haul roads. c The control is built into the equation in the emissions inventory. A drop height of 12 m has been assumed. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 10

After the application of these control factors to the uncontrolled emission rates, the resulting emissions are shown in Table 2.3. The control factors adopted are the default values contained within the Best Practice Report (Donnelly et al., 2011). Table 2.3: Summary of particulate matter emissions with current controls in place Mining Activity TSP PM 10 PM 2.5 (t/year) (t/year) (t/year) Topsoil Removal - Dozers/Excavators stripping topsoil 3.3 0.5 0.3 Topsoil removal - Sh/Ex/FELs loading and rehandling topsoil 0.6 0.3 0.0 Topsoil removal - Hauling topsoil to topsoil stockpile 14.2 3.3 0.3 Topsoil removal - Emplacing topsoil 0.4 0.2 0.0 OB - Drilling 10.8 5.6 0.3 OB - Blasting 35.4 18.4 1.1 OB - Sh/Ex/FELs loading OB 6.3 3.0 0.4 OB - Dragline removing OB 405.9 71.0 6.9 OB - Hauling to emplacement 828.8 192.3 19.2 OB - Dozers on O/B 197.8 32.6 20.8 OB - Rehandling O/B 2.2 1.0 0.2 OB - Emplacing OB at dumps 16.5 7.8 1.2 CL - Drilling 1.8 1.0 0.1 CL - Blasting 3.0 1.6 0.1 CL - Dozers ripping 397.0 114.4 12.7 CL - Loading ROM to trucks 155.4 23.1 3.0 CL - Hauling ROM coal to dump hopper 195.2 45.3 4.5 CL - Unloading ROM coal at stockpile/hopper 111.0 16.5 2.1 CL - Rehandle ROM coal at stockpile/hopper 0.5 0.3 0.0 CL - Unloading ROM coal at ROM Pad 222.0 33.1 4.2 CL - Crushing 14.9 6.6 0.0 CL - Loading product coal stockpile 159.8 23.8 3.0 CL - Conveyors at CHPP 0.1 0.1 0.0 CL - Dozers at CHPP 0.0 0.0 0.0 CL - Loading Rejects 47.1 6.2 0.8 CL - Hauling Rejects 18.2 8.5 0.8 CL - Emplacing Rejects 47.1 6.2 0.8 CL - Loading coal to trains 0.4 0.2 0.0 WE - Exposed areas including OB dumps - unwatered 471.9 236.0 35.4 WE - Exposed areas including OB dumps - watered 26.2 13.1 2.0 WE - Active coal stockpiles 96.9 48.4 7.3 Dozers on rehab 106.2 25.1 11.1 Grading roads 11.3 4.0 0.4 Total 3,608.3 949.3 139.1 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 11

Figure 2.1: Watering of haul roads Figure 2.2: Water sprays on ROM hopper 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 12

Figure 2.3: Partially enclosed conveyors Figure 2.4: Water sprays at conveyor transfer points 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 13

Figure 2.5: Water sprays at active coal stockpiles 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 14

2.3 Activities Rank Existing Controls 2.3.1 Ranking by emissions with current controls The calculated emissions from the mining activities (controlled) listed in Table 2.3 were combined into activity groups corresponding to those listed in the Guideline, and ranked from highest to lowest according to their total mass. In accordance with the Best Practice Guideline, the top four ranked activities according to estimated mass particulate emissions for TSP, PM 10 and PM 2.5 are shown in bold in Table 2.4, Table 2.5 and Table 2.6. Table 2.4: Activity groups ranked by TSP emissions in 2011 (with current PM controls) Rank Mining activity Emissions (tonnes/year) % of total 1 Hauling on Unsealed Roads 1,042.2 28.9 2 Wind Erosion on Open Areas 498.2 13.8 3 Material Transfer Coal (includes loading trucks) 440.0 12.2 4 Material Transfer OB 414.4 11.9 5 Bulldozers on Coal 397.0 11.0 6 Bulldozers on OB 304.0 8.4 7 Loading Coal Stockpiles 159.8 4.4 8 Trucks Unloading coal 158.1 3.1 9 Wind Erosion and Maintenance - Stockpiles 96.9 2.7 10 Blasting 38.3 1.3 11 Topsoil - Non-EPA Activity Category 18.5 1.1 12 Trucks Unloading OB 16.5 0.5 13 Drilling 12.6 0.3 14 Graders 11.3 0.3 15 Train Loading 0.4 0.01 TOTAL 3,608.3 100 Table 2.5: Activity groups ranked by PM 10 emissions in 2011 (with current PM controls) Rank Mining activity Emissions (tonnes/year) % of total 1 Wind Erosion on Open Areas 249.1 25.9 2 Hauling on Unsealed Roads 246.0 26.2 3 Bulldozers on Coal 114.4 12.1 4 Material Transfer OB 75.0 7.9 5 Material Transfer Coal (includes loading trucks) 69.4 7.3 6 Bulldozers on OB 57.7 6.1 7 Wind Erosion and Maintenance - Stockpiles 48.4 5.1 8 Loading Coal Stockpiles 23.8 2.5 9 Trucks Unloading coal 22.7 2.1 10 Blasting 19.9 1.7 11 Trucks Unloading OB 7.8 1.5 12 Drilling 6.6 0.7 13 Topsoil - Non-EPA Activity Category 4.3 0.5 14 Graders 4.0 0.4 15 Train Loading 0.2 0.02 TOTAL 949.3 100 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 15

Table 2.6: Activity groups ranked by PM 2.5 emissions in 2011 (with current PM controls) Rank Mining activity Emissions (tonnes/year) % of total 1 Wind Erosion on Open Areas 37.4 26.9 2 Bulldozers on OB 31.9 22.9 3 Hauling on Unsealed Roads 24.6 17.7 4 Bulldozers on Coal 12.7 9.1 5 Material Transfer Coal (includes loading trucks) 8.0 5.7 6 Material Transfer OB 7.5 5.4 7 Wind Erosion and Maintenance - Stockpiles 7.3 5.2 8 Loading Coal Stockpiles 3.0 2.2 9 Trucks Unloading coal 2.9 1.5 10 Trucks Unloading OB 1.2 1.4 11 Blasting 1.2 0.8 12 Topsoil - Non-EPA Activity Category 0.7 0.5 13 Drilling 0.4 0.3 14 Graders 0.4 0.3 15 Train Loading 0.03 0.02 TOTAL 139.1 100 The ranking differed according to the particle size, and each of the following activities was ranked in the top four for at least one particle size: Material transfer of overburden. Material transfer of coal (includes loading trucks). Hauling on unsealed roads. Wind erosion on open areas. Bulldozers on coal. Bulldozers on overburden. 2.4 Emissions with Potential Additional BPM 2.4.1 Identification of additional BPM This section of the report presents the additional BPM available for each of the five highest ranked mining activities as well the other mining activities. The percentage reduction from overall estimated emissions at the site has also been shown. In each case, the information on control effectiveness was again taken from the Best Practice Report (Donnelly et al., 2011) and used to calculate the percentage reduction from overall site emissions. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 16

Best Practice Control Hauling on unsealed roads Reduction from 75 km/hr Vehicle speed to 50 km/hr restrictions Reduction from 65 km/hr to 30 km/hr Surface improvements Surface treatments Table 2.7: Mass emissions applying best practice measures (kg/y) % control Emission Resultant Best Practice Emissions (tonnes) TSP PM 10 PM 2.5 % change in % change in % change in total Emission total Emission total emissions emissions emissions 40-75% 261 to 625 12% to 22% 62 to 148 10% to 20% 6 to 15 7% to 13% 50-85% 156 to 521 15% to 25% 37 to 123 13% to 22% 4 to 12 9% to 15% Pave the surface >90% 417 17% 98 16% 10 11% Low silt aggregate 30% 730 9% 172 8% 17 5% Oil and double chip surface 80% 208 23% 49 21% 5 14% Watering (standard procedure) 10-74% Current practice - - - - - Watering Level 1 (2 L/m 2 /h) 50% Current practice - - - - - Watering Level 2 (>2 L/m 2 /h) 75% Current practice - - - - - Watering grader routes 50% Current practice - - - - - Watering twice a day 55% Current practice - - - - - Dust suppressants 45%-84% Lower control < than current, higher = 667 Higher control = 11% Higher control = 157 Higher control = 9% Higher control = 16 Higher control = 6% 90t to 220t: 40% Current practice - - - - - Other Use of larger vehicles 140t to 220t. 20% 834 6% 197 5% 20 4% 140t to 360t: 45% 573 13% 135 12% 14 8% Conveyors >95% 208 23% 49 21% 5 14% Wind erosion on open areas Avoidance Minimise pre-strip 100% per m 2 of pre-strip avoided Current practice - - - - - Current practice Watering 50% (10% of area - - - - - watered) Surface stabilisation Wind speed reduction Chemical suppressants 70-84% 80 to 149 10% to 12% 40 to 75 19% to 22% 6 to 11 19% to 23% Paving and clearing >95% 25 13% 12 25% 2 26% Application of gravel to stabilise disturbed open 84% 80 12% 40 22% 6 23% areas Rehabilitation goals 99% Current practice - - - - - Fencing, bunding, shelterbelts or in-pit dump 30-80% 100 to 349 4% to 11% 50 to 174 8% to 21% 7 to 26 8% to 22% Vegetative ground cover 70% 149 10% 75 19% 11 19% 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 17

Resultant Best Practice Emissions (tonnes) TSP PM 10 PM 2.5 Best Practice Control % control % change in % change in % change in Emission total emissions Emission total emissions Emission total emissions Wind erosion and maintenance - stockpiles Avoidance Bypassing stockpiles 100% reduction in wind erosion for coal bypassing stockpiles 0 3% 0 5% 0 5% Watering 50% Current practice - - - - - Chemical wetting agents 80-99% 3 to 55 6% to 8% 1 to 28 12% to 15% 0.2 to 4 12% to 15% Surface Surface crusting agent 95% 14 7% 7 14% 1 14% stabilisation Carry over wetting from 80% 19 2% 10 4% 2 4% load in Silo with bag house 95-100% 0 to 5 2.6% to 2.7% 0 to 2 4.9% to 5.1% 0 to 1 5% to 5.3% Enclosure Cover storage pile with a tarp during high winds 99% 1 3% 0.5 5% 0 5% Vegetative wind breaks 30% 68 1% 34 2% 5 2% Reduced pile height 30% 68 1% 34 2% 5 2% Wind speed Wind screens/wind fences 75->80% 19 to 24 2% to 2.1% 10 to 12 3.9% to 4.1% 1 to 2 3.9% to 4.2% reduction Pile shaping/orientation <60% 39 2% 19 3% 3 3% Erect 3-sided enclosure around storage piles 75% 24 2% 12 4% 2 4% Material transfer of overburden (includes dragline and rehandling) Excavator Minimise drop height Reduce from 3 m to 1.5 m: 30% Current practice - - - - - Minimise drop height Reduce from 30 m to 5 m: 70% 129 8% 25 6% 3 4% Reduce from 10 m to 5 m: 40% 259 5% 50 4% 5 3% Dragline Modify activities in windy conditions Not quantified - - - - - - Water application 50% 215 6% 41 4% 4 3% Minimise side casting Not quantified - - - - - - Bulldozers on overburden, coal and rehab Minimise travel speed and distance Not quantified - - - - - - Keep travel routes and materials moist 50% 351 10% 86 9% 22 16% Blasting Design: delay shot to avoid unfavourable weather conditions Not quantified - - - - - - Design: minimise area blasted Not quantified - - - - - - Drilling Dry collection Fabric filters 99% 0.4 1% 0.2 2% 0.01 1% Cyclone 80-90% 4 to 8 1% to 1.1% 2 to 4 1.9% to 2.1% 0.3 1% Wet Water injection sprays while drilling 3-96% NIOSH document, 70% Current practice - - - - - 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 18

Resultant Best Practice Emissions (tonnes) TSP PM 10 PM 2.5 Best Practice Control % control % change in % change in % change in Emission total emissions Emission total emissions Emission total emissions Graders Grader speed reduction from 16km/hr to 8 km/hr 75% Current practice - - - - - Material transfer coal (includes loading and dumping ROM coal) 50% reduction in dumping emissions for coal bypassing ROM stockpile Avoidance Truck or loader dumping ROM coal Truck or loader dumping to ROM bin Bypass ROM stockpiles Emissions associated with 0 to 299 8% to 17% 0 to 46 5% to 10% 0 to 5 4% to 8% forming coal into stockpiles (e.g. by dozer push) would be reduced by 100% for bypassing coal Minimise drop height (10m to 5m) Reduce from 10 m to 5 m: 30% Current practice - - - - - Water sprays on ROM pad 50% 299 8% 46 5% 5 4% Current practice Water sprays on ROM bin 50% (sprays on or sprays on ROM pad hopper) - - - - - Enclosed dump hopper (3 sides and a roof ) 70% 179 12% 28 7% 3 6% Enclosed dump hopper (3 sides and a roof ) plus 85% 90 14% 14 8% 2 7% water sprays Enclosure with control device 90-98% 12 to 60 15% to 21% 2 to 9 9% to 10% 0.2 to 1 7% to 8% Conveyors and transfers Application of water at transfers 50% 0.1 0.002% 0.03 0.003% 0.001 0.001% Conveyors Wind shielding - roof or side wall 40% 0.1 0.001% 0.04 0.003% 0.001 0.001% Wind shielding - roof AND side wall 70% 0.04 0.002% 0.02 0.004% 0.001 0.001% Belt cleaning and spillage minimisation Not quantified - - - - - - Transfers Enclosure 70% 0.04 0.002% 0.02 0.004% Enclosure and fabric filters - - - - - - - Stacking and reclaiming product coal Avoidance Bypass coal stockpiles 100% reduction in stacking 0 4% 0 3% 0 2% 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 19

Resultant Best Practice Emissions (tonnes) TSP PM 10 PM 2.5 Best Practice Control % control % change in % change in % change in Emission total emissions Emission total emissions Emission total emissions emissions for coal bypassing stacker Variable height stack 25% 120 1% 18 1% 2 1% Loading coal Boom tip water sprays 50% 80 1% 12 1% 2 1% stockpiles Telescopic chute with water sprays 75% 40 2% 6 2% 1 2% Bucket wheel, portal or Unloading product bridge reclaimer with water stockpiles application 50% 80 3% 12 1% 2 1% Loading product coal to trains Water sprays 50% 0.2 0.01 0.1 0.01 0.02 0.01 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 20

3 PRACTICABILITY AND COSTS OF IMPLEMENTING ADDITIONAL BPM This section provides an assessment of the practicability associated with the implementation of each of the best practice measures identified in Section 2.4. As outlined in the Guideline, the assessment takes into consideration the following criteria: Regulatory requirements. Environmental impacts. Safety implications. Compatibility with current processes and proposed future developments. Measures considered not practical on these grounds and are not considered any further in this regard. Table 3.1 presents a summary of the assessment for each of the seven main particulate producers among the top four across the three particle size categories. To summarise, the practicable measures are: Hauling on unsealed roads Chemical suppressants. Wind erosion of exposed areas Vegetative ground cover. Unloading ROM coal to the ROM pad Water sprays. Train load out Water sprays. The following practicable measures could be implemented should the Drayton South Project be approved: Unloading ROM coal to the dump hopper: o Enclosed (3 sides) plus water sprays. Loading product coal stockpiles: o o Variable stack height. Boom tip water sprays. It should be noted that while Drayton Mine are considering the use of dust suppressants on haul roads, the emission factors and control efficiencies used in this report are generic, and the current real-world situation may be different. Moreover, the optimisation of PM control depends upon factors which are not defined explicitly in the Best Practice Report (such as evaporation rate, amount of dust suppressant applied, etc.) As noted above, there are inherent site specific uncertainties and the high cost of reducing emissions from haul roads. Drayton Coal will therefore evaluate the options in more detail based on trials and site-specific data, and will then decide whether to commit to adopting this control on a permanent basis. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 21

Table 3.1: BPM to reduce particulate matter emissions from haul roads Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility with current processes and proposed future development Practicable Y/N Evaluation Comments from Mine Vehicle speed restrictions Surface improvements Surface treatments Reduction from 75 km/hr to 50 km/hr Reduction from 65 km/hr to 30 km/hr Pave the surface Low silt aggregate Oil and double chip surface Watering (standard procedure) Watering Level 1 (2 40-75% N Y N More trucks would increase noise levels, diesel usage and GHG emissions N - More trucks would increase mobile plant interactions increasing risk of incidents N - Reduced productivity of operation and increase maintenance. N Truck speed is limited to 60km/h. Average speed is well below this. 50-85% N Y N As above N As above N As above N Not assessed. >90% N Y N Increase in surface runoff 30% N Y Y Y 80% N Y N Increase in surface runoff Y N N Y - Currently reject material is applied to haul roads. This material is working well on haul roads. Y N N N A paved surface is not practice due to the short term nature of haul roads. Tracked equipment movements would result in a high level of maintenance. Has been considered. Not implemented due to cost An oil and double chip surface is not practical due to the short term nature of haul roads. Tracked equipment movements would result in a high level of maintenance. 10-74% Y - - - - - - 50% Y - - - - - - 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 22

Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility with current processes and proposed future development Practicable Y/N Evaluation Comments from Mine Other L/m 2 /h) Watering Level 2 (>2 L/m 2 /h) Watering grader routes Watering twice a day Dust suppressants Use of larger vehicles 75% Y - - - - - - 50% Y - - - - - - 55% Y - - - - - - 45%- 82% 90t to 220t: 40% 140t to 220t. 20% 140t to 360t: 45% Conveyors >95% N N Y Not assessed - - - N Approval necessary N Approval necessary Y N - Suppressants increase the slipperiness of the road surface leading to potential traffic incidents Y N - water is currently used with good results. The need to rework haul roads on a regular basis is impractical. All haul roads are used for tracked machinery and dragline which is incompatible with many suppressants. N - Current infrastructure would not support larger trucks. There is potential for larger trucks under the proposed Drayton South Project. Y/N dependant on trial and costing Not assessed Not assessed N N N Further costing necessary to determine cost of suppressants. Increasing truck sizes for last 5 years of mine life is impractical. Use of conveyors is impractical due to the immobility of conveyors around the mine site. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 23

Table 3.2: BPM to reduce particulate matter emissions from wind erosion on open areas Practicality Evaluation Best Practice Control % control Curren t Use Regulatory Environmental Safety Compatibility with current processes and proposed future development Practicable Y/N Evaluation Comments from Mine Avoidance Surface stabilisation Wind speed reduction Minimise prestrip 100% per m 2 of prestrip avoided Y - - - - - Watering 50% Y - - - - - Chemical suppressants Paving and clearing Application of gravel to stabilise disturbed open areas Rehabilitation goals Fencing, bunding, shelterbelts or in-pit dump Vegetative ground cover 70-84% >95% N N Y Y Y N N N Not consistent with EA N - Impacts on rehabilitation and water infiltration / drainage N N N 84% N Y Y Y N N 99% Y - - - - - 30-80% N Y Y Y 70% N Y Y Y N - Trees are planted on site under the current rehab program which may also act as a windbreak. Y - Trial has occurred previously. Uncertain of further use. N Y Y - Current restrictions of stripping one strip in advance of mining face and the minimisation of open pre-stripped areas. Watering currently is restricted to areas the water cart can reach. Restriction of access to all exposed areas. Paving all areas is not practical due to the short term nature of exposed areas. Application of gravel is not practical on exposed areas due to accessibility and the short term nature of areas. Y - Drayton currently have annual rehab targets. Not assessed. Further costing necessary. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 24

Table 3.3: BPM to reduce particulate matter emissions from material transfer of overburden (includes dragline and rehandling) Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility with current processes and proposed future development Practicable Y/N Evaluation Comments from Mine Excavator Dragline Minimise drop height Minimise drop height Modify activities in windy conditions Water application Minimise side casting Reduce from 3 m to 1.5 m: 30% Reduce from 30 m to 5 m: 70% Reduce from 10 m to 5 m: 40% Not quantified Y - - - - - N Y - - - Y- In line with current practices - N Y - - - Y - - - - - 50% N Y Y Y Y N Not quantified Y - - - - - Drop height is currently kept to a minimum. The lower the drop height the more economical the process. Y - Dragline drop height is minimised to the lowest possible height Y - dragline currently modifies activity in windy conditions. Has been implemented onsite while working in dusty material The dragline is designed to side cast material. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 25

Table 3.4: BPM to reduce particulate matter emissions from bulldozers on overburden, coal and rehab Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine Minimise travel speed and distance Keep travel routes and materials moist Not quantified Y - - - - - 50% N Y Y Y Y N Dozers are currently planned for economy that incorporates minimising travel distance. Travel routes well watered, material not moist. It is not practical to keep all material moist. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 26

Table 3.5: BPM to reduce particulate matter emissions from remaining activities Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine Wind erosion and maintenance stockpiles Avoidance Surface stabilisation Enclosure Bypassing stockpiles 100% reduction in wind erosion for coal bypassing stockpiles N Y Y Y Y N Watering 50% Y - - - - - Chemical wetting agents Surface crusting agent Carry over wetting from load in Silo with bag house 95-100% N Cover storage pile with a tarp during high winds 80-99% N Y Y Y Y N A small % (approx. 2%) of coal bypasses stockpiles. It is impractical to bypass all coal due to coal process. Coal stockpiles currently have water sprays that are utilised as required. Coal in product stockpiles has been processed and is moist. Coal on stockpiles for extended periods is managed with water sprays. 95% N Y Y Y Y N As above. 80% N Y Y Y Y N As above. N Approval necessary N Visual impacts. 99% N Y Y Y N N N- Handling of tarp in high winds is unsafe. N - Would result in loss of production and delays due to not being able to reclaim coal while covered with a tarp. N Not practical due to the size of silo/s needed to replace current capacity Not assessed. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 27

Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine Wind speed reduction Blasting Vegetative wind breaks 30% Y - - - - - Reduced pile height 30% Y - - - - - Wind screens/wind fences Pile shaping/orientation Erect 3-sided enclosure around storage piles Design: delay shot to avoid unfavourable weather conditions 75->80% N <60% N 75% N N Approval necessary. N Approval necessary. N Approval necessary. Y Y N - Tree clearing would be necessary. Y Y N - Trees currently inhibit fencing. N - Current infrastructure designed for current orientation of stockpiles. N - Not practical due to access and would result in clearing of trees that currently provide a windbreak. Not quantified Y - - - - - Design: minimise area blasted Not quantified Y - - - - - Y N N N Trees have been allowed to grow adjacent to Drayton Product Stockpiles to the North, East and West providing a wind break. Current maximum height of stockpiles is 15 m. Not assessed. Not assessed. Not assessed. Blasts are currently delayed if conditions are not suitable. Blasting time is restricted due to approved times and internal sleep criteria. Blast area is minimised to maintain 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 28

Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine Drilling Dry collection Wet economies of scale. Fabric filters 99% N N Y Y Y N Drills have dust Cyclone 80-90% N N Y Y Y N suppression currently 3-96% NIOSH Water injection document, sprays while drilling 70% Y Y - - - - Not assessed. Graders Grader speed reduction from 75% Y Y - - - - Not assessed. 16km/hr to 8 km/hr Material transfer coal (includes loading and dumping ROM coal) 50% reduction in dumping emissions for coal bypassing ROM stockpile Avoidance Truck or loader dumping ROM coal Truck or loader Bypass ROM stockpiles Minimise drop height (10m to 5m) Water sprays on ROM pad Water sprays on ROM bin or sprays Emissions associated with forming coal into stockpiles (e.g. by dozer push) would be reduced by 100% for bypassing coal Reduce from 10 m to 5 m: 30% N Y Y Y Y N Y Y - - - - 50% N Y Y Y Y Y 50% N Y Y Y Y Y A small % of coal is bypassed the ROM. The majority is not bypassed due to coal quality considerations. Operators reduce drop height to minimum for dust and economy purposes. Infrastructure would need to be added to this area. Water sprays on hopper but not at 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 29

Practicality Evaluation Best Practice Control % control Current Use Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine dumping to ROM bin on ROM pad Enclosed dump hopper (3 sides and a roof ) Enclosed dump hopper (3 sides and a roof ) plus water sprays Enclosure with control device Conveyors and transfers Application of water at transfers Wind shielding - roof or side wall Conveyors Transfers Wind shielding - roof AND side wall Belt cleaning and spillage minimisation 70% N 85% N 90-98% N N Approval necessary N Approval necessary N Approval necessary Y Y Y Y Y Y N - Will be implemented if Drayton South is approved. N - Will be implemented if Drayton South is approved. N - Will be implemented if Drayton South is approved. N/Y dependant on Drayton South approval. N/Y dependant on Drayton South approval. N/Y dependant on Drayton South approval. ROM pad. Further costing necessary. Further costing necessary. Further costing necessary. 50% Y Y - - - - Current practice. 40% Y Y - - - - 70% Y Y - - - - Implemented where possible. Many conveyors cannot be roofed due to the nature of infrastructure. Not quantified Y Y - - - - Current practice. Enclosure 70% Y Y - - - - Enclosure and fabric filters - N Y Y Y Y N Transfer points currently enclosed. Not necessary due to water sprays at transfer points 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 30

4 PROPOSED TIMEFRAME FOR IMPLEMENTATION OF BEST PRACTICE MEASURES Based on the evaluation presented in Section 3, the following BPM are proposed for implementation by Drayton. Table 4.1: BPM to be implemented Activity/BPM Proposed implementation date Hauling on unsealed roads Chemical suppressants (ongoing use dependant on trials). Trial date:2013 Wind erosion of exposed areas Vegetative ground cover. 2013 Unloading ROM coal to the ROM pad Water sprays. 2013 Train load out Water sprays. 2013 The following practicable measures could be implemented should the Drayton South Project be approved. Table 4.2: BPM to be implemented should the Drayton South Project be approved Activity/BPM Unloading ROM coal to dump hopper Enclosed (3 sides). Enclosed (3 sides) plus water sprays. Loading product coal stockpiles Variable stack height. Boom tip water sprays. Proposed implementation date End of financial year 2015 End of financial year 2015 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 31

5 MONITORING AND TRACKING THE EFFECTIVENESS OF BPM AT DRAYTON COAL MINE Long-term monitoring is required to ensure that any reductions in emissions following the introduction of control measures are maintained over the lifetime of the mine, and will enable the operator to check that progress is being made towards environmental targets. On the 9 May 2012, the EPA held an information session and workshop to provide feedback to consultants and mines on the PRPs received to date. A key outcome of the workshop was that the control effectiveness of both existing and proposed PM controls should be measured and reported, as follows: Control effectiveness must be supported by: - Key performance indicator - Monitoring method - Location, frequency and duration of monitoring - Monitoring data records and analysis - Management procedures A common approach to tracking the effectiveness of such measures involves the use of key performance indicators (KPIs). Performance indicators should be meaningful, measureable, repeatable, comparable and auditable. Drayton will therefore track the long-term effectiveness of PM controls at the Drayton Mine through the use of KPIs, and four potential KPIs are proposed below. 5.1 KPI-1 - Emissions of PM 10 per tonne of ROM coal This headline KPI will provide an indication of the overall dustiness of the mine relative to its production, as a combination of all activities. It makes direct use of the emissions inventory compiled for the PRP process, and rather than simply measuring the total dust emissions, it is expressed as a proportion of the production rate. The value of the KPI will change each year as the generation of PM 10 is dependent on any changes in the distribution of mining activities such as lengths of haul roads and dozer hours. However, if these things remain relatively similar each year, a downward trend in the KPI over time will indicate the effectiveness of the control measures that are implemented. The KPI will be recalculated on an annual basis (AEMR/NPI reporting period) using the PRP emissions inventory spreadsheet. The annual recalculation will be relatively straightforward, requiring input data on intensity for each mining activity (e.g. material production rates, VKT, dozer hours etc.). It is also recommended that this KPI is improved by using site specific input data (silt content, moisture content, control efficiencies). An outline of the monitoring recommended for improvements to this KPI is outlined in Section 5.5. Further details for this KPI are outlined in Table 5.1, along with objectives and targets and reporting requirements. If adopted for the mine, a site specific procedure would be developed for this KPI. Based on the emission estimates presented for this PRP, the existing kg PM 10 / t ROM ratio for Drayton is 0.18 kg/t, which is reasonably low. This is the baseline against which this KPI can be tracked. The equivalent ratio for uncontrolled emissions would be 0.35 kg/t. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 32

5.2 KPI-2 Control of PM 10 Emissions This KPI will quantify the progress of the mine towards achieving best practicable controls for PM 10 emissions (Donnelly et al, 2011). It provides a measure of improvement of the mine as a whole by combining the efficiency of each individual control. It is therefore not dependent on such variables as productivity, VKT and bulldozer hours, as is the case for KPI- 1. The current control measure for each mining activity is compared with the best practically achievable control measure for that activity. This ratio is then weighted according to the contribution of that uncontrolled activity to the total uncontrolled annual emission. A mine that is operating with best practicable controls on activities producing the majority of emissions would score close to 100. This KPI will be recalculated annually using the PRP emissions inventory spreadsheet, and it is recommended that it be improved by using site-specific data, as outlined in Section 5.5. Further details of the KPI, including the metric, objectives, targets and reporting requirements are given in Table 5.1. If adopted for the mine, a site-specific procedure would be developed for this KPI. 5.3 KPI-3 Opacity (Visible Dust Emissions) This KPI is designed to provide an indication of visibility dust emissions at the mine site. There are various methods for monitoring opacity, and the chosen method would determine the monitoring locations and intervals. Further details for this KPI are outlined in Table 5.1, including the various methods and standards for measurement, objectives and targets and reporting requirements. If adopted for the mine, a site specific procedure would be developed for this KPI, relevant to the chosen opacity monitoring method. 5.4 KPI-4 Watering intensity for haul roads Hauling on unpaved roads is the major contributor to total dust emissions. Controlling emissions from this activity is therefore important, and there are a number of measures listed in the Best Practice Report which can produce significant reductions. An existing control efficiency of 75% is assumed for this PRP report, equivalent to Level 2 watering (75%), as per the Best Practice Report. The actual site specific control efficiency for the Drayton haul roads for watering is unknown, and it is recommended that this is determined. Once the site specific control efficiency is measured, and the equivalent watering rate determined, it is used for tracking and reporting against this KPI. Where the site specific control efficiency is found to be less than 75%, the watering application rate required to achieve 75% control can be determined and used for tracking and reporting against this KPI. Further details for this KPI are outlined in Table 5.1 including objectives and targets and reporting requirements. If adopted for the mine, a site specific procedure would be developed for this KPI, relevant to the chosen monitoring method. The options for the measurement of site specific control efficiencies are outlined in Table 5.3. 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 33

( ) Where: K1y is the value of KPI-1 (in kg of PM 10 per tonne of ROM coal) in year y E PM10 is the total emission of PM 10 from the mine (in kg, with current controls) in year y M ROM is the mass of ROM coal (in tonnes) mined in year y Table 5.1: KPIs for BPM KPI-1 Annual emissions of PM 10 per tonne of ROM coal (kg PM 10/t ROM) Metric Method / Standard Objective / Target Frequency Report This KPI is defined as follows: Annual dust emissions inventory using PRP emissions inventory Include in AEMR template This KPI is defined as follows: ( ) Where: K2y is the value of KPI-2 (%) in year y CF i is the current control factor for activity i in year y CF i-b is the best practicable control factor for activity i This KPI is defined as follows: Where: K3y is the value of KPI-3 (dimensionless) in year y y is the average opacity in year y This KPI is defined as follows: ( ) Where: K4y is the value of KPI-3 (in litres per vehiclekilometre) in year y W Haul is the total amount of water applied to haul roads in year y VKT Haul is the total number of vehiclekilometres on haul roads in year y KPI-2 PM 10 Emission Control (%) Annual dust emissions inventory using PRP emissions inventory template KPI-3 Visible Dust Emissions (Opacity) Visual Observations US EPA Method 9 Visual Determination of the opacity of emissions from stationary sources San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 8011 General Requirements (Appendix A Visual Determination of Opacity) Digital Imagery ASTM WK 30382 New Test Method for Determining the Opacity of Fugitive Emissions in the Outdoor Ambient Atmosphere, Using Digital Imagery KPI 4 - Watering Intensity for Hauling (L/VKT) N/A Downward trend in PM 10/ROM ratio until best practicable control is achieved Progression towards 100% <20% Opacity at source - hauling, open pit and stockpile area <20% Opacity at source No less than the level of watering (L/VKT) to achieve the site specific control efficiency. (Derived through site specific determination of watering control effectiveness) Annual (matching 12 month reporting period for AEMR/NPI) Annual (matching 12 month reporting period for AEMR/NPI) Weekly Continuous Annual Include in AEMR Weekly operators log. Include in AEMR 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 34

5.5 Recommendations for Ongoing Improvement of KPIs Another key message from the EPA information sessions (referred to as Key Message 2 (EPA, 2012)) was the use of site specific data in deriving PM emissions estimates for the PRP, such as: Material parameters moisture and silt contents Meteorology Vehicle weight, speed, traffic volume Activity data areas disturbed, stockpiles, material transfer The available site specific data have been provided by the mine and used for the PM emissions estimates presented in the report. specifications, and activity data. These data include meteorology, vehicle However, due to time constraints the sampling and analysis of material properties was not completed. For ongoing evaluation against the KPIs, it is recommended that improvements are made to emission estimates using site specific data and site specific control efficiencies are determined. The recommended monitoring for input into the KPIs are outlined in Table 5.2. Measurement methods for determination of site specific controls for water are outlined in Table 5.3. Table 5.2: Site specific measurements for improvements to KPI-1 Parameter Measurement Method / Standard Frequency % moisture content (overburden dumps, ROM coal and product coal) US EPA AP42 Appendix C.1 Procedures for Sampling Surface / Bulk Dust Loading US EPA AP42 Appendix C.2 Procedures for Laboratory Analysis of Surface Dust Loading Samples Annual % silt content (overburden dumps, ROM coal and product coal, haul roads) US EPA AP42 Appendix C.1 Procedures for Sampling Surface / Bulk Dust Loading US EPA AP42 Appendix C.2 Procedures for Laboratory Analysis of Surface Dust Loading Samples US EPA AP42 Chapter 13.2.5 Annual Threshold Friction Velocity for Annual coal piles and exposed areas Dust Extinction Moisture Level AS 4156.6 2000 Coal Preparation Part 6: One off (for (DEM 1 ) Determination of dust/moisture relationship for coal each coal type (ROM and product coal) or new seam) Notes: 1 DEM is defined as the moisture level at which dustiness is reduced to a level of 10 (i.e. minor dust emissions expected during bulk handling operations). 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 35

Table 5.3: Site specific control efficiencies Parameter Measurement Method / Standard Frequency Site Specific Watering Control Effectiveness Mobile emissions monitoring device for unpaved roads. Method uses equipment designed to make direct measurements of dust concentrations as a result of vehicle traffic on the roadway as it travels. The system was developed by PAEHolmes for ACARP (publication pending). Control Efficiency determined by linear relationship between control efficiency and moisture content of surface, shown below. Seasonal Seasonal Moisture Ratio (M) as defined by US EPA AP 42 Chapter 13.2.2 Unpaved Roads: Moisture Content determined by: ASTM D2216-10 Standard Test Methods for Laboratory Determination of Water (Moisture) Content of Soil and Rock by Mass ASTM D1557-09 Standard Test Methods for Laboratory Compaction Characteristics of Soil Using Modified Effort (56,000 ft-lbf/ft (2,700 kn-m/m)) 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 36

6 CLOSING/CONCLUSIONS This study has been produced to address the requirements of the Coal Mine Particulate Matter Control Best Practice PRP as attached to the Drayton Coal Mine Environmental Protection Licence (EPL 1323) in December 2011. The methodology followed the steps in the Site-specific Determination Guideline, and the study identified the following activities as being the most important in terms of emissions of TSP, PM 10 and PM 2.5 with current controls in place: Material transfer of overburden. Material transfer of coal (includes loading trucks). Hauling on unsealed roads. Wind erosion on open areas. Bulldozers on coal. Bulldozers on overburden. Potential Best Practice control measures for the above activities as well as other activities at the mine were identified, and their practicability evaluated. From the work presented in the previous sections of the report it is clear that Drayton Mine already have a number of PM-control measures in place. The main control measures involve the application of water to unsealed haul roads, partially enclosed conveyors, minimising overburden drop height and water sprays at the dump hopper, coal stockpiles, drill rig, conveyor transfer points. Potential Best Practice control measures for the above activities were identified, and their practicability evaluated. The PM-control measures that were deemed practicable at the Drayton were: To summarise, the practicable measures are: Hauling on unsealed roads Chemical suppressants. Wind erosion of exposed areas Vegetative ground cover. Unloading ROM coal to the ROM pad Water sprays. Train load out Water sprays. The following practicable measures could be implemented should the Drayton South Project be approved: Unloading ROM coal to the dump hopper: o Enclosed (3 sides) plus water sprays. Loading product coal stockpiles: o o Variable stack height. Boom tip water sprays. Four potential key performance indicators have been presented for tracking the long-term effectiveness of the PM controls at Drayton Mine. Again, it is recommended that improvements are made to emission estimates using additional site-specific data, and that 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 37

site-specific control efficiencies are determined on a regular basis, to improve the reliability of the indicators. 7 REFERENCES Donnelly S-J, Balch A, Wiebe A, Shaw N, Welchman S, Schloss A, Castillo E, Henville K, Vernon A and Planner J (2011). NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and / or Minimise Emissions of Particulate Matter from Coal Mining. Prepared by Katestone Environmental Pty Ltd for NSW Office of Environment and Heritage June 2011. EPA (2011). Coal Mine Particulate Matter Control Best Practice - Site-specific determination guideline. November 2011. New South Wales Office of Environment and Heritage, Sydney. November 2011. http://www.environment.nsw.gov.au/resources/air/20110813coalmineparticulate.pdf USEPA (1998). AP-42 Compilation of Emission Factors, Section 13.2.4 Western Surface Coal Mining, October 1998. http://www.epa.gov/ttnchie1/ap42/ch11/final/c11s09.pdf USEPA (2004). AP-42 Compilation of Emission Factors, Section 11.19.2 - Crushed Stone Processing and Pulverized Mineral Processing, August 2004. http://www.epa.gov/ttnchie1/ap42/ch11/final/c11s1902.pdf USEPA (2006a). AP-42 Compilation of Emission Factors, Section 13.2.2 - Unpaved Roads. November 2006. http://www.epa.gov/ttnchie1/ap42/ch13/final/c13s0202.pdf USEPA (2006b). AP-42 Compilation of Emission Factors, Section 13.2.4 - Aggregate Handling And Storage Piles, November 2006. http://www.epa.gov/ttnchie1/ap42/ch13/final/c13s0204.pdf 6763 Drayton PRP FINAL Report 270612 PUBLIC.docx 38

Appendix A: Copy of PRP as contained in Drayton Coal EPL Licence 6763 Drayton PRP FINAL Report 270612 PUBLIC.Docx A-1

Source: EPL Licence 1323 21-Dec-2011 6763 Drayton PRP FINAL Report 270612 PUBLIC.Docx A-2

Appendix B: Copy of Coal Mine Particulate Matter Control Best Practice Site Specific Determination Guideline August 2011 6763 Drayton PRP FINAL Report 270612 PUBLIC.Docx B-1

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6763 Drayton PRP FINAL Report 270612 PUBLIC.Docx B-4